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Baylor BU Internal Audit Outside Activities and Interests Outside Activities and Interests FAQs
  • Outside Activities and Interests FAQs

Outside Activities and Interests FAQs

What are Outside Activities and Interests?

Activities and interests performed outside of Baylor. Common examples include, but are not limited to, consulting, providing expert witness services, service on a board, having ownership interests, outside employment, outside teaching, and outside research.

What is a Conflict of Interest?

A conflict of interest may occur when there is divergence between an individual’s private personal financial relationships or interests and their employment obligations to Baylor such that a reasonable person might question whether the employee’s actions or decisions are determined by considerations of personal benefit, gain, or advantage, rather than the best interests of Baylor.

What is a Conflict of Commitment?

A conflict of commitment may occur when an employee’s time spent on outside activities or interests exceeds reasonable time limits when the employee’s primary responsibility is to Baylor.

Why do Baylor employees have to complete an Outside Activities and Interests (OAI) disclosure?

Baylor University is committed to ensuring that faculty and staff conduct the affairs of Baylor in accordance with the highest ethical and legal standards, free from conflict.  It is for the benefit and protection of the individual employee to disclose and manage any outside activities and interests.  Failure to disclose research conflicts may jeopardize the investigator’s and/or Baylor’s ability to receive federal grant funding.

Do I really have to disclose my family members’ outside activities and interests?

You should disclose outside activities and interests of your family members if the activities or interests are connected in some way to Baylor.  If they are not connected to Baylor, then you do not need to disclose them.

Why does Baylor have an Outside Activities and Interests Committee (OAIC)?

The OAIC is tasked with reviewing staff, faculty, and researcher disclosures of outside activities and interests.  The OAIC’s role is to determine whether an individual’s relationship with an external entity creates a situation that could introduce bias or undue influence into the activities conducted at Baylor, and, if found, to recommend and implement strategies to reduce, manage, or eliminate the conflict.

If I am a researcher, do I have to complete an annual disclosure and a research disclosure?

No, you will only have one disclosure profile that is routed to the pertinent offices for review.  Two separate offices review the disclosures after the employee’s supervisor.

How will I know if I am required to complete or update a disclosure?

You will receive an email notification from the CARA system to complete your disclosure profile.  

Who needs to complete an annual disclosure at Baylor University?

All benefits-eligible Baylor employees must complete a disclosure. Research regulations may require others to complete a disclosure.

How often do I have to complete or update my disclosure?

Employees will complete the disclosure profile upon beginning employment with Baylor, every year on or around September 12, and within 30 days of acquiring a new activity or interest.

Researchers may have to review and update their disclosure profile as they are associated with new research projects.

Do I need to disclose earnings from a previous employer?

No, you do not need to disclose earnings from an employer prior to beginning your career at Baylor.

Do I need to disclose all of my investments and equity holdings?

Employees (including researchers) are required to disclose ownership interests or investments in a company or business held by the employee or their family (including equity, stock, or stock options) that relate to the employee’s institutional responsibilities and exceed $5,000. This does not include investment vehicles, such as mutual funds and retirement accounts, as long as you do not directly control the investment decisions made in those vehicles.

How long will it take to complete a disclosure?

It will depend on how many outside activities and interests you need to disclose.  Some individuals will take roughly a minute to complete the disclosure, while others may take 30-45 minutes. 

Who decides if what I disclose constitutes a conflict?

Your supervisor, Internal Audit or Research Compliance, and the OAIC will make determinations of an actual or perceived conflict of interest or commitment.

Should I expect to be contacted by Internal Audit or Research Compliance?

You may be contacted if there are follow-up questions, if clarifications are requested, or if it is determined that you have a conflict of interest or commitment.

Do I need to disclose affiliations with foreign entities?

You must obtain pre-approval and disclose any and all relationships and activities with a foreign entity to Baylor.  Collaborations or authorship you share with an individual from a foreign country must be disclosed but do not currently require pre-approval.

Do I need to disclose outside activities and interests that do not exceed one day per week or $5,000?

No, unless the outside activity or interest involves a foreign entity, directing a program or lab outside of Baylor, teaching outside of Baylor, or taking a role in a start-up company.

I had a management plan before the new CARA system was live. Is that still in place?

Yes, existing management plans remain in effect for the duration of your outside activity or interest.

Can my administrative assistant complete the disclosure for me?

No, Baylor employees are responsible for completing and submitting their own outside activities and interests disclosure.

What happens if I don’t complete the disclosure?

Baylor expects employees to complete their disclosure form.  Failure to comply with the policies in place and the overall process may lead to disciplinary action up to and including termination for violation of Baylor policies.  There may be additional consequences for researchers who fail to comply, including negative actions for failing to comply with NSF, PHS, or other sponsoring research entities.

Do I have to re-enter my information again next year?

No, the CARA system will retain your responses and allow them to be edited during future disclosure cycles.

Who should I contact if I have questions about completing the disclosure process?

Please email Internal_Audit@baylor.edu, or send research-specific questions to ResearchCOI@baylor.edu. 

Who may I contact if I suspect a violation of the Baylor University Outside Activity and Interests Policy?

Contact Internal Audit to report your concerns, or you may file a report anonymously, via EthicsPoint.

How are the OAI disclosure forms reviewed?

Your supervisor will complete a review of the disclosure before routing your disclosure to either Internal Audit or to Research Compliance for a secondary review.  They will determine if your disclosure needs to be reviewed by the Outside Activities and Interests Committee (OAIC).

May I appeal the decision of the OAIC?

Yes, you can request an appeal.  Contact either Internal Audit or Research Compliance to initiate the appeal process.

What is sponsored travel and what am I required to report?

Sponsored travel is travel which is paid on behalf of the Investigator/employee and not reimbursed to the Investigator/employee.  If you or your family member has received sponsored travel, you should report it on your disclosure profile.

Am I required to complete training?

Training is made available to assist you with answering your disclosure profile questions, or with completing a review for one of your employees.  It is not required and is there as a resource to you.

Researchers must complete training on Conflicts of Interest through CITI at least every 4 years. Additional training for researchers may be required by federal regulation.

How often does the OAIC meet?

The OAIC meets monthly, beginning in October each academic year.

I have no outside activities or interests to disclose. Do I still need to submit a disclosure form?

Yes, your disclosure profile requires an annual update, which will be on or near September 12 every year.

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